throbber
In The Matter Of:
`
`SI GHT SO LTND TECHN O LO GIES, LLC
`a.
`APPLE INC.
`
`/USTI¡ü DOUGLAS TYGAR, Ph.D. - VoL L
`October 8,2012
`
`ffiffiffi"r,"ËFßffiffi ffiffiWW
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`LegãLink, ¡rrc.
`
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`$an F¡ancincç, üA g4'lú5
`Pholr*:415,357.43óÛ
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`
`Apple Exhibit 1018 page 00001
`
`

`

`UNITED STATES DISTRTCT COURT
`
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
`---ooo---
`
`SIGHTSOUND TECHNOLOG]ES, LLC,
`Plaint i ff,
`
`APPLE INC. ,
`
`Defendant.
`
`No. 2:11cv0L292-DWA
`
`DEpOSrrroN otr JUSTTN DOUGLAS TYGAR, Ph.D.
`October B, 2072
`
`ffiffiffiTåF&ffiffi ffiffipv
`
`Reported by:
`Natalie Y. Botelho
`CSR No. 9891
`
`Page 00002
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph. D
`
`10/B/2012
`
`Page 2
`
`INDEX
`
`INDEX OF EXAMTNATIONS
`
`trXAMTNATION BY MS. FUKUDA.
`
`---()(J()---
`
`No.
`Exhibit
`
`EXH]BITS MARKED FOR TDENTTF]CATION
`De s cript ion
`Declaration of J.D. Tygar, -
`Ph. D.
`
`65
`
`Exhibit 66
`
`Exhibit 61
`Exhibit 68
`
`Exhibit 69
`
`Exhibit 1 0
`
`Exhibit 1I
`
`Declaration of.....
`Responsive
`J. D. Tygar,
`Ph. D.
`of Sean M. Callagy
`Declarat ion
`Patent Number.
`United States
`5 , r9r, 5'7 3
`United States Patent Number.
`5,6'/5,134
`United States Patent Number
`5 , 966, 440
`SightSound's and Apple's.
`. .
`Proposed Claim Constructions
`pursuant to Local Patent Rule
`4.2 and Appendix LPR 4.2
`
`---oOo---
`
`Page
`...5
`
`Page
`. .I4
`
`1A
`
`)1JI
`
`5B
`
`5B
`
`tro
`
`119
`
`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`www . merri l lcorp . com/ law
`
`Page 00003
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2012
`
`Page 3
`
`BE IT REMEMBERED THAT, or Monday, October
`B, 2012, coÍrmencing at the hour of B:02 o' clock a . m.
`of the said dry, at the law offíces of ROPES & GRAY,
`3 Embarcadero Center, 3rd Floor, San Francisco,
`California, before me, NATALIE Y. BOTELHO, a
`Certified Shorthand Reporter for the State of
`California, personally appeared JUSTIN DOUGLAS
`TYGAR, Ph.D., a witness in the above-entltted court
`and cause, who, being by me f irst duly s\,vorn/ was
`examined in said cause.
`
`APPEARANCE OF'COUNStrL
`
`FOR PLATNTIFF:
`ARNOLD & PORTER LLP
`BY: JAMES A. DiBOISE, ESQ.
`3 Embarcadero Center, 'ÌLin Floor
`San Francisco, CA 9AIIT-4024
`(415) 41r-328r
`j ames . diboiseGaporter. com
`
`trOR DEFENDANT:
`ROPES & GRAY LLP
`BY: CHTNG_LEE FUKUDA, trSQ.
`I2II Avenue of the Americas
`New York, NY 10036-8104
`(2r2) 596-9000
`ching-1ee . fukudaGropesgray. com
`
`ALSO PRESENT:
`Ted Hoppe, Videographer
`
`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`w\,vw . merri I lcorp . com/1aw
`
`Page 00004
`
`

`

`JUSTTN DOUGLAS TYGAR, Ph. D
`
`r0/B/2012
`
`Page 4
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`THtr VIDEOGRAPHtrR: Here begins volume I,
`videotape No. I,
`in
`the deposition
`of Justin Douglas
`Tygar, in the matter
`of SoundSight
`( sic)
`Apple Inc. ,
`the Unlted States
`Technologies versus
`tn
`the Western
`District Court, for
`District of
`Action No.
`2: IIcv0 1 292-DWA
`Pennsylvania, Civil
`Today's date is October Bth, 2012. The
`time on the video monitor is B:03. The vldeo
`operator today is Ted Hoppe, a notary public,
`contracted by Merrill Court Reporting, San
`Francisco, California.
`This videotaped deposition
`is taking place at 3 Embarcadero Center in San
`Francisco.
`
`Counsef, would you please voice identify
`yourselves and state whom you represent.
`MS. FUKUDA: Ching-Lee Fukuda with Ropes
`Gray, representing the defendant, Apple Inc.
`MR. DiBOfSE: James DiBoise with Arnofd &
`Porter/ representing the plaintiff.
`THtr VIDEOGRAPHER: Natalie, could you
`please sh/ear the witness in.
`
`&
`
`JUSTIN DOUGLAS TYGAR, Ph.D.,
`as follows
`being first duly sworn, testified
`
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`23
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`.AZ1
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`atrz-)
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`800-869-9132
`
`Merrill- Corporation
`
`San Francisco
`www . merriÌ lcorp . com/law
`
`Page 00005
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D. - IO/B/2012
`
`Page 5
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`THE VIDEOGRAPHER: Please Proceed.
`EXAMTNATION BY MS. FUKUDA
`MS. FUKUDA: Q. Good morning, Dr. Tygar.
`Would you provide your fuÌl name for the record,
`
`n_l arca?
`
`Good morning. Justin, J-U-S-T-I-N;
`A.
`Douglas, D-O-U-G-L-A-S; Tygar, T-Y-G-A-R.
`Thank you. Dr. Tygar, what is Your
`O.
`current home address?
`spelled
`I2B5 Alvarado
`A.
`A-L-V-A-R-A-D-O Road, Berkeley, California 94105.
`And Dr. Tygar, you've had your deposition
`O.
`taken before, correct?
`A.
`Yes.
`About how many times?
`O.
`I don't know exactly, but something about
`A.
`20 times.
`And were those depositions always taken in
`O.
`your capacity as an expert?
`With one exception, yes.
`A.
`What's that one excePtion?
`A.
`I got married in the Republic of Taiwan,
`A.
`and Taiwan has a funny law regarding foreigners
`They have to go to
`marryíng Taiwanese nationals.
`their country's representatlve office, basically
`
`the
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`
`MerrilÌ Corporatíon - San Francisco
`www . merri I lcorp . com/ law
`
`Page 00006
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph. D.
`
`r0/B/2012
`
`Page 6
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`equivalent of the consulate, and formally sign a
`statement which is a deposition saying that they are
`not currently married. Because in the United States
`we don't have records as they do in Taiwan for which
`you could prove that you're not married. So they
`ask you to do that.
`it
`later on
`I assume so that if
`turns out that someone gets married twice,
`they have
`a basis to brinq a case against the person who did
`that.
`
`go to the
`married, I had to
`So to get
`called the
`Consulate
`it's
`the U.S
`effectively
`of the funny
`i n Taiwan
`American Tnstitute
`because
`diplomatic relations between the U. S. and Taiwan and
`It's not technically a consulate, but it's
`China.
`legally equivalent to a consulate. And I had to
`I was
`have a deposition taken basically stating
`single before I got married.
`Thank you. Now, you're here today to
`O.
`testify on behalf of SightSound regarding claim
`issues, right?
`construction
`A.
`Yes -
`Have you testified before with respect to
`O.
`claim construction
`issues?
`
`À
`
`O.
`
`Vac
`
`And about how many times?
`
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`arZJ
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`800-B 69-9732
`
`Merril-f Corporation - San Francisco
`www . merrillcorp . com/Iaw
`
`Page 00007
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D
`
`r0/B/2012
`
`Page 1
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`I don't have an accurate count
`I am not
`A.
`because I
`of that. And my estimate is likely
`to figure
`that
`haven't really sat down and tried
`to be more off.
`out, my estimate is likety
`But
`It could be plus or
`maybe about ten times or so.
`minus five.
`
`And you've testified before on behalf of
`issues,
`with regard to c,l-aim construction
`
`a.
`SightSound
`ri ght ?
`Yes. At least I remember testifying at a
`A.
`Markman hearing in a court in tr{estern Pennsylvania.
`For how many different matters have you
`O.
`been retained by SightSound as a technical expert or
`consultant ?
`I'm not sure I understand your question.
`A.
`You are retained by SightSound for this
`a.
`case against Apple, correct?
`That's right.
`A.
`Were you retained for other cases by
`O.
`SightSound?
`
`A
`
`Vac
`
`How many other cases?
`a.
`Welf, it's been over a period of time, So
`A.
`I'm not 100 percent sure I can give you an accurate
`answer, but f was retained in a case against a
`
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`27
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`22
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`a1LJ
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`24
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`25
`
`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`ww\,v. merrillcorp. com/f aw
`
`Page 00008
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`L0/B/2012
`
`Page B
`
`in
`
`company called CDNow, and I was retained in the case
`I
`of a company that had used the name Napster.
`I
`believe that \,{as actually Roxio. And I also
`\,^/as formally retained or
`don't know we qualified
`it
`not, but there \,vas a patent
`re-examination-examination of some patents by Arthur
`to help the
`Hair for which I wrote some declarations
`patent office analyze those patents. So that's what
`f remember as I sit here now.
`Okay. Other than the cases that you had
`O.
`just mentioned, were you retained by SightSound in
`any other matter?
`I don't remember any other instance as I
`A.
`sit here now.
`Other than being retalned in the
`O.
`in your capacity as an expert of
`capacity
`Sightsound, are you employed in any manner by
`S i ght Sound?
`A.
`No.
`Are you employed in any manner by
`O.
`any manner by DMT Licensing?
`I was not a
`No.
`A.
`what is DMT Licensing?
`of
`familiar with DMT Licenslng.
`Are you employed in any manner by General
`a.
`
`sorry.
`I don't
`
`I'm not aware
`not
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`Merrill Corporation
`
`San Francrsco
`www . merrillcorp . com/law
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`Page 00009
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`

`

`JUSTTN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2012
`
`Page 9
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`No, not
`no.
`nave you ever consulted for General
`u---,
`
`trlectric?
`A.
`v.
`^
`Electric?
`WelI, âs I mentioned, during the
`A.
`there was a re-examination of
`re*examination of
`the Hair patents, certain
`some of what I'11 calf
`patents with a named inventor of Arthur Hair, which
`I believe are the patents-in-suit
`in this case, so
`those the Hair patents, and there was a
`I'll
`call
`re-exam of some of the Hair patents. And at that
`that there was counsel from General
`time I recafl
`Efectric who had contacted me in context with that
`re-examination.
`And who \,vas that counsel?
`A.
`I don't remember his name"
`A.
`in either
`Do you have any interest
`O.
`SightSound or General Electric?
`Do you mean financial
`A.
`That's correct.
`O.
`So all of my investment funds are put into
`A.
`mutual funds that are controlled by Fidelity or
`they are
`Vanguard or TIAA-CREF, and they're broad
`broad mutual funds that attempt to mimic the
`I,
`behavior of certain stock market indices .
`
`interest?
`
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`22
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`23
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`24
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`25
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`
`Merrill Corporation
`
`San Francisco
`www . merrillcorp. com/faw
`
`Page 00010
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`L0/B/2012
`
`Paqe 10
`
`though, have not Looked at the specific portfolio of
`stocks that they invest in, so I don't know whether
`these mutual funds have any investment in General
`Electrlc or SightSound or for that matter any other
`company. I simply invest in them in an attempt to,
`to a stock
`for example, 9et performance similar
`such as the NASDAQ 500, for
`index, such as the
`
`interest?
`
`in the outcome of
`
`example.
`So you are not a\ivare of any financial
`O.
`in either SightSound or General Electric?
`interest
`That's correct.
`A.
`Do you have any interest
`O.
`this action?
`Again, you're asking a financial
`A.
`That's correct.
`a.
`A.
`No.
`Is there any other kind of interest you
`a.
`have in mind?
`I
`interest.
`intellectual
`A.
`Welf, there's
`I think these are interesting patents.
`think that
`I was no J-onger engaged b,y Sightsound, I
`So even if
`would probably look at a newspaper to try to see how
`the case came out in the end.
`What drd you do to prepare for your
`O.
`deposition today?
`
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`20
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`ZJ
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`Z4
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`25
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`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`www . merri I lcorp . com/ f aw
`
`Page 00011
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2012
`
`Page 11
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`0B :74:32
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`0B:14:35
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`0B:14:39
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`I had some in-person and
`I had a
`A.
`I
`I'm sorry,
`telephone meetings with counsel at
`always get the name of the counsel mixed up because
`I keep on wanting to say Arnold Palmer. You know, f
`keep thinklng of the famous drink and the famous
`I had meetinqs with
`golfer. Arnofd & Porter.
`counsel at Arnold & Porter last week, oh Tuesday, a
`telephone meeting on Wednesday, another meeting on
`Thursday
`sorry
`Sunday.
`And how long was your in-person meeting
`O.
`last Tuesday?
`It was a hour and a half.
`A.
`Who did you meet with?
`a.
`I met with Mr. DiBoise, Ms. Lane, and a
`A"
`guy named Sean. I think that's spelled S-E-A-N, and
`I don't know his last name.
`Anyone else?
`O.
`A.
`No.
`And your telephone conference on
`O.
`Wednesday, who was that with?
`You know, I vvas sick }ast week,
`A.
`l!
`d5
`-LL
`I'm
`afraid
`I was running a fever,
`turned out.
`So
`so it's
`the telephone conference,
`Sây, when I had
`a
`me. But I think that all of those
`bit of a haze to
`of the telephone conference, as
`people were part
`
`to
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`Merrill Corporation
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`San Francisco
`www . merril lcorp . com/ law
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`Page 00012
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`

`

`JUSTIN DOUGLAS TYGAR, Ph.D
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`r0/B/2012
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`Page 12
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`wefl as an attorney named Nick, whose last name I
`don't remember.
`And what about your meeting yesterday?
`O.
`The meeting yesterday l,^/as with the same
`A.
`three people that I met with on Tuesday. Plus
`fellow Nick was on the
`telephonicalLy, Nick, this
`was connected to the meeting.
`And for how long did you meet yesterday?
`O.
`About four hours.
`A.
`How long was your telephone conference on
`
`a.
`
`Wednesday?
`
`was Thursday, actually.
`I think that
`Ah.
`A.
`on Thursday. You know,
`The telephone conference was
`was sick at the time.
`I don't remember, because I
`is ít
`\das about an hour.
`My recollection
`And Dr. Tygar, ãs you sit here today, can
`A.
`you think of any reason why you wouldn't be able to
`and completely today?
`answer my questions truthfully
`I'm confident I can answer your questions
`A.
`truthfully
`and compJ-etely today.
`Thank you. Now, Dr. Tygar, you had
`O.
`in this case regardinq
`submitted two declarations
`or your opinions on claim
`your position
`issues; is that right?
`construction
`That's my recollection.
`A.
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`24
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`800-869-9132
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`Merrill Corporation
`
`San Franclsco
`www . merri Ì1corp . com/ law
`
`Page 00013
`
`

`

`0B:16:09
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`0B:16:17
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`0B : 16:22
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`0B :76: 42
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`JUSTlN DOUGLAS TYGAR, Ph. D
`
`70/B/201,2
`
`Page 13
`
`And as you sit here today, can you tell me
`the statements in those
`alI
`believe that
`hether you
`and accurate, in your
`true
`are all
`declarations
`opini on ?
`
`a w
`
`Yes, I do believe they're all
`
`true and
`
`A
`
`accurate.
`
`And do
`opinions
`
`those two
`regarding
`
`declarations embody all
`claim construction
`issues
`
`¡:ca?
`
`Yes, they do.
`If you remember, in your declaration you
`forth what you believe is the levef of
`right?
`in the art,
`skill
`
`O.
`of your
`1n this
`
`A.
`
`a.
`had set
`ordinary
`
`A.
`
`And so your opinions in those declarations
`in the
`on how a person of ordinary skill
`understand the disputed terms in the
`the Sightsound patents in 198B; is that
`
`a.
`are based
`art would
`context of
`right ?
`
`to that.
`Many of the opinions relate
`Were there any opinions that did not set
`a person of skill
`in the art would view
`in 19BB?
`f don't remember.
`I'd need to look at my
`
`I'd need to look
`declarations
`to
`
`at
`
`A.
`
`a f
`
`A
`
`my
`
`orth how
`the terms
`
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`I9
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`20
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`2L
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`22
`
`aaL)
`
`24
`
`25
`
`800-869-9732
`
`Merrill Corporation
`
`San Francisco
`v/ww. merrillcorp. com/f aw
`
`Page 00014
`
`

`

`JUSTTN DOUGLAS TYGAR, Ph.D
`
`r0/B/2012
`
`Page I4
`
`a few dozen pages long, So T need
`that that
`to verify
`declarations
`
`they're, you know,
`to look through my
`was correct.
`your oprnfons rn your
`Okay. Would
`A.
`from the perspective
`declarations change if
`in the art as of 1993?
`of a person of ordinary
`declarat ions ?
`Could I Ìook
`A.
`them both for you.
`Sure. Let me
`a.
`mark
`of
`Let-'s mark as
`Exhibit 64 a copy
`declaration of J.D. Tygar, Ph
`, dated
`D
`make that 65
`September 1Lln, 2072. Let me
`(Whereupon Exhibit 65 was marked for
`identification.
`MS. FUKUDA: And let's mark as Exhibit 66
`a copy of the responsive declaration of J. D. Tygar,
`Ph.D., dated September 2BLh, 2012.
`(Whereupon trxhibit 66 was marked for
`identification.
`MS. FUKUDA: Q. So Dr. Tygar, do You
`recognize Exhiblts 65 and 66 as copies of the two
`that you submitted in this case
`expert declarations
`regarding clalm construction
`issues?
`WeIl, âS I sit here now/ I haven't had a
`A.
`chance to look through them carefully, but they
`appear to be.
`
`any of
`viewed
`skill
`at my
`
`)
`
`)
`
`0B:17:13
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`0B:19:17
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`0B:19:19
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`0B:I9:44
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`0B:19:41
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`0B:19:50
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`20
`2I
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`22
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`23
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`24
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`25
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`Merrill Corporation
`
`San Francisco
`www . merri I lcorp . com/ law
`
`Page 00015
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D
`
`r0/B/2012
`
`Page 15
`
`^
`
`Àra
`
`Now, now that you have your declarations
`O.
`in front of you, let me lust qo back to my questions
`in the art.
`about a person of ordinary ski1l
`So
`your opinions in these two declarations are based on
`in the art would view
`how a person of ordinary skill
`the claim terms as used in the context of the
`SightSound patents
`correct ?
`as of 1988,
`that form, yes.
`them were of
`Many of
`A.
`terms for which you
`aware of any
`\¿.
`You
`did not use that standard?
`THE WITNESS: Could T ask You, Madam Court
`Reporter, to read back the question?
`(Record read. )
`THE WITNESS: Not as I sit here, ilo.
`If you see one todaY
`MS. FUKUDA: Q.
`during the course of the deposition for which you
`in the art
`did not apply a person of ordinary sklll
`as of 19BB standard, let me know.
`I'11 do my best.
`A.
`Okay. And my second question \,vas/ if you
`a.
`were to view the terms in the context of the
`Sightsound patents from the perspective of one of
`in the art as of 1993, would any of
`ordinary skill
`your opinions change?
`With your permission, I'll
`A.
`
`0B:19:58
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`0B:20:00
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`0B:20:03
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`0B:20:06
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`0B:21:00
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`0B:21:05
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`0B:21:08
`0B :2I: 12
`0B :2I: 16
`0B :2I:2I
`
`take a few
`
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`11
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`T6
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`T1
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`1B
`I9
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`20
`2I
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`22
`
`23
`
`24
`
`25
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`800-869-9l.32
`
`MerrilÌ Corporation
`
`San Franclsco
`www . merri I lcorp . com/Ìaw
`
`Page 00016
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D
`
`r0/B/2012
`
`Page L6
`
`moments to review the opinions that I expressed in
`the declaration so that I can answer your question.
`Okay. You can certainly do that, b,ut if
`O.
`you think you're going to need more than a few
`minutes, then maybe we'11 move ot, and as we talk
`ab,out it, you can keep this question in mind.
`it's
`taking
`Okay. Let me start, and if
`A.
`too long, let me know. Okay?
`O.
`
`Okay.
`
`is
`
`(Pause. )
`THE VVITNESS: So one point that has
`changed is, on page B, if you look at the top line,
`is true, ât that time/ some telephonic
`I say, "It
`transmissions (e.q.,
`took place
`local calls)
`this
`entirely along copper wires."
`I'm sorry,
`of my first declaration.
`page B of my
`It's Exhibit 65.
`MS. FUKUDA: Q. Okay.
`So that was much less true
`That's right.
`
`A.
`in 1993.
`And how is that less true in 1993?
`O.
`by I993l many local switches had
`The
`A.
`updated and did not use purely twisted pair means to
`So by 1993, it was no lonqer
`switch phone calls.
`while there t^/ere still
`the case that
`some
`telephonic transmissions that took place along
`
`0B :21 :23
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`0B :21 :21
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`1-9
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`20
`2I
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`22
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`23
`
`24
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`25
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`800-869-9132
`
`Merrill Corporatlon
`
`San Francisco
`w\,vw - merrillcorp. com/law
`
`Page 00017
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`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2012
`
`Page I1
`
`copper wires, there were much fewer in number.
`And how about today?
`O.
`That trend has increased. So even today
`A.
`this
`is
`even today,
`is much less
`this
`the
`this phenomena has continued. So even fewer local
`take place using entirely copper wires.
`calls
`Do you have any estimate as to, you know,
`O.
`what percentage of the telephonic transmissions back
`took place entirely alonq copper
`in 19BB was
`
`WILCS
`
`Í
`
`A.
`
`As T sit here now/ I can't give you that
`
`As I sit here right now/ I can't give you
`
`How about today? Can you give an estimate
`
`number.
`O.
`at all?
`A.
`a number.
`O.
`OkaY.
`With your permission, I'll
`continue
`A.
`there are
`reading through the decl-arations to see if
`is with regard to
`this
`any other statements that
`I believe, are there statements that
`your question,
`in the
`f made about individuals of ordinary skill
`in the
`tatking about people of ordinary skill
`art,
`which I believe were true but
`art in 1988, which
`which might not have been true of someone of
`
`0B:24:II
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`0B:24:13
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`1B
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`79
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`20
`2I
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`22
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`a')LJ
`
`24
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`25
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`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`www . merri llcorp . com/ law
`
`Page 00018
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2072
`
`Page 18
`
`0B:25:30
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`0B :25:33
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`0B :28 : 48
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`.:R-)R- Aq
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`0B :28 :52
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`in the art in 1993.
`ordinary skill
`Sure. Go ahead.
`A.
`(Pause. )
`THE WITNESS: So I've only quickly skimmed
`In skímming through them, except for
`through these.
`the statements that I
`that one sentence I noticed,
`made regarding a person of ordinary skill of the art
`circa 19BB woufd have would apply equally or in
`some cases would be even strong for a person of
`in the art circa 1993.
`ordinary skitt
`MS. FUKUDA: Q. Besides that one
`okay. Forget that question.
`sentence/ can you
`Let me ask another one. You said in some cases it
`for a person
`woul-d be even stronger/ your opinions,
`in the art in 1993. Which cases
`of ordinary skill
`are you thinking of?
`Ìet me find the
`and I'm
`A.
`For example
`thls
`right passage here. Oh, So, for example, in
`in paragraph
`is not an exhaustive list, but 1n 19
`I write,
`"In 198B/ one
`19 of my opening declaration,
`in the art would have
`of reasonable skill
`understood, " quote, "'telecommunications lines, "'
`fiber-optic
`unquote, "to include telephone lines,
`cab,Ie, wireless networking, and several other
`mediums of electronic communication (such as
`
`1 2 3 4 5 6 1 oO 9
`
`10
`
`11
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`72
`
`13
`
`I4
`
`15
`
`L6
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`L1
`
`1B
`
`I9
`
`20
`2I
`
`22
`
`23
`
`24
`
`25
`
`800-B 69-9132
`
`Merrilf Corporation
`
`San Francisco
`\,vww . merrillcorp
`
`. com/law
`
`Page 00019
`
`

`

`JUSTIN DOUGLAS TYGAR, Ph.D. - IO/B/2072
`
`Page 19
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`0B :30:54
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`0B:31:00
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`0B:32:01
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`0B :32 :0 4
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`0B:33:40
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`telephones and microwave transmissions) .
`cellular
`These terms would have covered transmission using
`fiber-optic
`cables, and
`metal wire, non-metallic
`wireless transmission usinq electromagnetic
`particles. " So the diversity of different
`communications lines had increased between 19BB and
`L993. For example, one woufd have added more items
`to
`such as Internet-based phone calls
`such as
`So that's one example of a point where
`list.
`this
`it woufd be a stronger point.
`Can you think of any other example?
`O.
`Okay. Let me go through and fook.
`A.
`( Pause. )
`THE WITNESS: So in my oPening rePort,
`paraqraph 24, I mentioned that in 1988, there are
`already a number of well-known wireless networking
`standards. There \,^/ere even more in 1993, including
`the early versions of the 802.f 1 standards. So
`while one 1n 19BB woul-d have been aware of local
`wireless networking protocols/ a person in 1993
`would have known even more.
`I'11 continue looking.
`
`( Pause. )
`THE WITNESS: So those are the passages
`that jump out at me as I bríefly
`reread these
`
`1 2 3 4 t
`
`rJ
`
`6 1 B o
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`10
`
`11
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`r2
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`I6
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`L1
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`1B
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`I9
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`JUSTIN DOUGLAS TYGAR, Ph.D
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`r0/B/20r2
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`declarations.
`MS. FUKUDA: Q. Okay. I'm going to turn
`to Exhibit 65, page 3. And looking
`your attention
`at paragraph 9, if you skip to the second sentence/
`you say here, "For present purposes/ a 'person of
`is one with an
`in the art'
`ordinary skill
`undergraduate degree in computer scíence or
`efectrical engineering or an equivalent levef of
`from working in the industry
`knowledge and ability
`for an appropriate number of years. " Just a couple
`of questions. What do you mean by "an equivalent
`l-evel of knowledge and abifit-y"?
`Oh, welf, sometimes we see people who
`A.
`don't have a degree in electrical engineering or
`computer science. Maybe their degree is in physics.
`And after receivíng a degree, they wísh to work 1n
`the computer industry. So after a certain number of
`familiar with the
`years, they become sufficiently
`ideas that they basically know as much as someone
`who has an undergraduate degree. So that would be
`an example of equivalent experience.
`You had mentioned working for a number of
`O.
`years. Ab,out how many years to achieve that
`equivalent level of knowledge?
`Well, it would depend on the individual.
`A.
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`JUSTlN DOUGLAS TYCAR, Ph.D
`
`r0/B/2012
`
`Page 2L
`
`It would also depend on the background. So someone
`with a degree in physics or mathematics might find
`this sort of transition easier than someone with a
`degree in philosophy, for example. Although I
`certainly know people with backgrounds in all
`areas who educate themselves and became very
`in the
`competent, at least people of ordinary skill
`for example, I could easily
`It could be
`art.
`imagine that someone, you know, depending on the
`two to
`individual and the nature of work, after
`seven years, could have achieved that level of
`knowledge.
`
`those
`
`And you say, "from working in t.he
`O.
`industry. " Which industry are you referring
`to?
`the subject matter of the
`Well, it's
`A.
`the electronics
`the computer industry,
`patent.
`It's
`I mean, in that
`industry. And in particular,
`I think that this applies, but in
`context,
`given the topic of these patents, that
`particular,
`for example, the computer
`would incfude working in,
`of video or
`industry, which involved digitization
`audio information.
`just trying
`Okay. f'm
`re ferred
`tafk about
`hen you
`to seven years of working, are
`
`to understand.
`to the two
`earl ier
`those two to seven
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`San Francisco
`w\,{w . merri I J-corp . com/law
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`

`JUSTIN DOUGLAS TYGAR, Ph.D. - LO/B/2012
`
`Page 22
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`years, do they all require that the industry be in
`of video or audio information?
`the digitization
`Certainly not. So the test is not the
`A.
`number of years that you've been workíng. The test
`ls that you have an equivalent level of knowledqe.
`So when someone has an equivalent level of knowledge
`from working in the area, then that person would be
`ready to move ahead.
`ready to
`For example, the founder of Apple
`I'm not sure if he was the
`computers, Steve Jobs
`founder. At least he's very cÌoseÌy associated with
`I understand from press reports
`Apple computers.
`that he never received an undergraduate degree. Yet
`I think that I would certainly classify him as a
`in the arL,
`person of at least ordinary skitf
`because through his work, he had developed an
`equivalent level of knowledge.
`Yeah, I think I'm just trying
`to
`O.
`three industries,
`understand. You had listed
`of
`computers, electronics, and the diqitization
`I'm just trying
`to get
`video or audio information.
`a sense for whether you're sayíng that a person of
`in the art needs to have equivalent
`ordinary skill
`three of those industries
`fevef of knowledqe in all
`or one of the three.
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`www . merril lcorp . com/1aw
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`

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`JUSTIN DOUGLAS TYGAR, Ph.D.
`
`r0/B/2072
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`I mean, ûo
`Well, ûo one ever would have
`A.
`I think I'm not
`I'm sorry.
`one would ever have
`understanding your question. Could you repeat your
`question, please?
`MS. FUKUDA: Can yoLt read it back?
`(Record read. )
`THE WTTNESS: I think your question's
`
`ambiguous.
`
`MS. FUKUDA: Q. Okay. Well, Your
`statement here says you think a person of ordinary
`ín the art is one with an undergrad degree in
`skill
`computer science or electrical engineering or an
`equivalent level of knowledge and ability
`from
`for an appropriate number of
`working in the industry
`years. So how would you go about determining
`whether somebody has reached the equlvalent level of
`from working in the industry
`knowledge and ability
`for an appropriate number of years?
`asking that
`Vrlell , if you're asking me
`A.
`question of me personally, since I am a professor of
`computer science, I was a professor of computer
`science in 1988, it would be very straightforward.
`I would have a brief conversation with the person
`the person had the same knowledge
`and find out if
`that a typical undergraduate person
`a typical
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`wr,vw . merri I I corp . com/ l-aw
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`

`JUST]N DOUGLAS TYG

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